The IRS released an advance version of Notice 2017-46 which details procedures for FFIs required to report U.S. TINs under FATCA Model 1 IGAs. In this advance notice, the IRS establishes that they will not determine that there is significant non-compliance with reporting obligations under an applicable Model 1 IGA during calendar years 2017, 2018, and 2019 because of a failure to obtain and report each required U.S. TIN. However, this will only occur provided that the reporting Model 1 FFI:

Obtains and reports the DOB of each account holder and controlling person whose U.S. TIN is not reported

Requests annually from each account holder any missing required U.S. TIN; and

Before reporting that relates to calendar year 2017 to the partner jurisdiction, searches its electronic records for missing U.S. TINs.